Our hospital members are asking thousands of questions about meaningful use Stage 2 regulations, with a large portion of requests related to the transitions of care objective.
Below are some of the most challenging questions our meaningful use experts have answered to help providers plan to meet this complex objective.
Can patients who refuse to have their information exchanged be excluded from the TOC objective?
Patients who refuse to exchange their information cannot be excluded from the measure denominators. CMS keeps the performance threshold at a moderate 50% for Measure 1 and 10% for Measure 2 in order to accommodate circumstances in which individual transitions cannot be counted in the numerator.
Does CMS provide leniencies if any of the required data elements are unavailable?
In circumstances in which there is no information available to populate one or more of the required data elements, either because the eligible hospital (EH) can be excluded from recording such information or because there is no information to record (e.g., laboratory test results), the EH may leave the field(s) blank and still meet the objective and its associated measures.
However, if at the time the summary of care (SOC) record is generated and the other data elements are available to populate the C-CDA, this information should be included as well.
Are TOCs based on unique patients?
No, the denominator for this objective is not constrained by unique patients. The concept of "unique patients" applies only if it is expressly defined in the measure itself. In the hospital setting, the denominator is based on "…all discharges from the inpatient department and after admissions to the ED when follow-up care is ordered by an authorized provider of the hospital."
Why a meaningful use picture is worth 1,000 pages
If an SOC record is successfully exchanged but the receiving provider does not read it, does that still count?
Yes, the transferring provider’s responsibility is to exchange the SOC record and get confirmation of receipt. Therefore, the transferring provider is not responsible for whether the receiving provider chooses to read or incorporate the SOC record.
A patient is discharged after a surgery, and his surgeon notes that the patient should follow up at both the provider’s outpatient clinic and with his primary care provider. How should the hospital count the denominator in this case?
At a minimum, one discharge would be equivalent to one TOC, regardless of the number of actual referrals. However, providers have the latitude to exceed the regulatory minimum and count each referral as a separate TOC, but a C-CDA must be provided to the receiving providers in both instances for them to count in the numerator. Hospitals must work with their EHR vendor to validate that their report can account for multiple referrals or transfers, or only a one-for-one referral or transfer.
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